in the Interest of K.T. and R.D.T., Children ( 2015 )

ACCEPTED
14-15-00504-CV
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
7/13/2015 4:19:43 PM
CHRISTOPHER PRINE
CLERK
CASE NO. 14-1S-00S04-CV
IN THE INTEREST OF § IN THE FOURTEENTH
§ FILED IN
14th COURT OF APPEALS
K.T. & R.D.T., § COURT OF APPEALS
HOUSTON, TEXAS
§ 7/13/2015 4:19:43 PM
Children. § AT HOUSTONCHRISTOPHER A. PRINE
Clerk
JOINT MOTION TO DISMISS APPEAL
TO THE HONORABLE JUDGES OF THE FOURTEENTH COURT OF APPEALS:
Appellant and appellees ask the Court to dismiss this appeal.
INTRODUCTION
1. Appellant is Elisa Marie Moreno; appellees are Richard Dale Touchstone and the
Office of the Attorney General Child Support Division.
2. Appellant perfected the appeal on June 8, 2015, when she filed a notice of appeal.
ARGUMENT & AUTHORITIES
3. The Court has the authority under Texas Rule of Appellate Procedure 42.1 (a)(2) to
grant this joint motion to dismiss.
4. The parties have reached an agreement to compromise and settle their differences
in the suit In the Interest ofKT & R.D.T, cause number 07-FD-2827 in the County Court at Law
No.2 of Galveston County, Texas. See Rule 11 agreement attached as exhibit 1.
5. The parties ask the Court to set aside the trial court's judgment without regard to
the merits and remand the case to the trial court for rendition of judgment in accordance with the
parties' agreement. TEX. R. APP. P. 42. 1(a)(2)(B).
CONCLUSION
6. The parties have reached an agreement to compromise and settle their differences
in the suit In the Interest ofKT & R.D.T, cause number 07-FD-2827 in the County Court at Law
No.2 of Galveston County, Texas. The parties ask the Court to set aside the trial court's judgment
without regard to the merits and remand the case to the trial court for rendition of judgment in
accordance with the parties' agreement.
PRAYER
7. For these reasons, the parties ask the Court to grant this joint motion to dismiss.
Costs on appeal should be taxed in accordance with the parties' agreement.
Respectfully submitted,
By: /s/ Julia C. Hatcher
JULIA HATCHER
Attorney for Appellant
State Bar No.: 24004692
1622 Campbell Lane
Galveston, TX 77551
Cell: (409) 599-6685
Fax: (409) 744-1283
Email: jhat788699@aol.com
AGREED:
By /s/ Lynette Briggs
LYNETTE BRIGGS
Attorney for Appellee, Richard Touchstone
State Bar No.: 24027109
P. O. Box 46
Hitchcock, TX 77563
Tel: (409) 986-6565
Fax: (409) 986-9189
Email: lbriggslaw@verizon.net
BY:~
DIANNA M. NORTON /K",f.: Ce~"f)
Attorney for Appellee, Attorney General of Texas
State Bar No.: 24052227 /JC(OJ'J,)~T
5300 FM 2004
LaMarque, TX 77568
Tel.: 409-986-7688
Fax: 409-986-9663
Email: csd-Iegal-603@texasattorneygeneral.gov
2
NO. 07FD2827
IN THE INTEREST OF § INCOUNTYCOURTATLAW
§
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NUMBER TWO
CHILDREN § GALVESTON COUNTY, TEXAS
Rule 11 AGREEMENT
1. ELISA MORENO'S CHILD SUPPORT SHA!t1 BE SET AT
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2. PARTIES AGREE THAT THE APPEAL SHALL BE ABANDONED AND FURTHER
ACTIONS IN THIS CAS~BY THE RULES OF CIVIL P03,0CEDURE AND _THE
TEXAS ``MILY CODE. c,",,\ \-e ,,\b"J,""'- b'--\ ,``\ ~&r'S\~\\
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. . aard Touchstone
Julia Hatcher attorney for Elisa Moreno
Texas Attorney General
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